NCUA Not Embarking On Any Type of CRA-Like Regulation

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After reading the recent column by Ed Roberts in The Credit Union Journal, we as Members of the NCUA Board felt compelled to provide readers an accurate report on the pilot initiative designed to collect data on the income distribution of members, the service being provided to those members, and the total compensation of the top tiered credit union officials.

Very importantly, the NCUA Board is not embarking on a Community Reinvestment Act (CRA)-like regulation. Nothing could be further from the truth. During the recent CUNA Governmental Affairs Conference, we believe it was clear to everyone that the three-member NCUA Board does not support any policy dictating CRA-like requirements for credit unions. This same position was repeatedly provided to NCUA staff involved in the development of the data gathering pilot project. Furthermore, the "Community Service Program" was placed on the pilot initiative. Once again, the NCUA has not instituted a new program, and there is no such name.

By way of background, Congress and the Government Accountability Office (GAO) have called on NCUA to review these issues and collect data supporting the measurement of credit union service. Over the next five months, the NCUA examiners will be collecting data demonstrating and measuring service to members, not constructing a new and cumbersome process. We must keep in mind that this is a first step to accurately quantify the variety of credit unions' service to all their members. This process will not present regulatory burdens to credit unions.

Public comment is also important and valued. We have appreciated hearing from those in the credit union community on the work they are doing to demonstrate service to their members, as well as comments on this initiative.

While NCUA is aware of anecdotal evidence of credit union outreach to people of modest means, the House Ways and Means Committee and the GAO have expressed an explicit desire to see quantifiable data. The pilot initiative developed by NCUA will allow the agency to collect data while not being burdensome on the random statistically selected 481 credit unions.

The column suggested that the initiative was designed by the Chairman's office. The NCUA staff developed the initiative in concert with all three Board Members, each of whom expressed a firm belief that the pilot initiative must be designed and carried out with extreme care and deliberation.

We are pleased with the progress thus far, and look forward to analyzing the data and assessing whether its methodology is complete so as to assure that Congress and GAO receive the most accurate information on credit unions' member service. Thank you for the opportunity to set the record straight.

JoAnn M. Johnson, NCUA Chairman

Rodney E. Hood, NCUA Vice Chairman

Christiane Gigi Hyland, NCUA Board Member

Alexandria, Va.

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